McKeel_ADD-2_AllenNov12.doc

ALLEN_SDsites_2012.fpS

TABLE 3a Filemaker Pro Layout 4, List Notes (2 pages)

1125/2012 ALLEN AUG-NOV 2012 AWE-DOE SITES 7

SITE PAID_CASES DR_APPROYE SITE_TYPE UR_FORM NOTES
(G31) General Steel 72 66 AWEINDEX —dingots, GSI is the INDEX SITE egainst which ell Allen proposed surrogate
ingot dat are assessed as “stringently justifies” for process

slices, 1 petitoners assert no Allen proposed SD site passes
itlets Slugs, derbies not subjected to NOT radiography et

166 during the AEC contract period. Kew

info indicates Betstron NDT siso wes done at GSI Nov~
Simonds Sew & Stee! 120 7 AWE ROLL rolled Site listed as GSI surrogate in Allen Aug 201 2 paper only. Omitted

“uranium — (rom Nov 2012 paper. Purpose of including this site was to show
metel” that airborne uranium activity wes higher during rolling
compared to after rolling. Rolled billet flat sheets of uranium
were not used at GSI 1953-66. during the AEC contrsct period.
Dates not in Fig. 1.

Chambersburg 0 CY) AWE SD slugs —-@ SROB/page numbers for this site in Allen Nov 2012 paper
differ from Allen Aug 2012 paper for same site, Slugs were not
used at GSI. This is confusing. TBD-6000 stug facility surrogste
site failed Board SD criteria. 6/28/12 TBD6K work group
meeting.

Chambersburg 0 2 AWE SO slugs Heating and forging of slugs caused higher airborne levels 30 that
«dt is possible some of the airborne contamination caused by
this work interfered with samples teken while laoging the
furnace.” Allen DCAS Aug. 2012 paper. Text and Fig, 3.40 nat.
clearly state the number of colé Ur sir samples.

Heald Machine 0 9 AWE SO. slugs —_ Site listed 93 GSI surrogate in Allen Aug 2012 paper only, as Fig.
2. Heald site was omitted from the Allen Nov 2012 paper. A
reason is not stated except Inst “although this activity may nol be
directly epplicedle to the movement of cold uranium metal...” Air
‘samples were taken from cooled mechine area during machining

RY LeBlond Mechine 0 9 AWE SO Dillets Billets were also used at GSI. However, size comparability of
Dillets sent to GSI by MCW and LeBlond site billet size nss not
deen documented conclusively, Fig. 4 of the Aug 2012 Allen peper
shows 3 samples of handled “cold” Ur, and 3 samples taken after
Dillet was bored, le, were not strictly colé when handled.

Toceo Induction C) o AWE SO slugs Slugs were not used st GSI. TBD- 6000 s1ug fecility surrogate site
failed Beard SD criteria, based on an SC&A review paper, at the
8/28/12 TBD6K work group meeting

Legend. Part A of Layout 4 (List Notes) adds the NOTES variable field to previous database report
variables. This part of the table highlights again that three of the 4 sites that are AWE and therefore
similar to the GSI AWE site, nevertheless used uranium slugs similar to the slug facility in TBD-6000 that
SC&A Board surrogate data criteria.

Summary of Layout 4, List Notes report. The notes field emphasizes dissimilarities
between the type of uranium form used for NDT radiography at the Index AWE site,
GSI, compared to David Allen’s surrogate AWE and DOE sites for uranium air samples
in his August and November GSI papers. Only uranium dingots and billets were sent
from MCW sites to GSI under AEC contract. Uranium slugs and derbies were not
handled at GSI. Betatron slices and ingots were used at GSI, and these forms are not
represented at the additional Allen surrogate sites. The Simonds Saw and Steel AWE
site did not yield relevant air samples to GSI. The SS&S was used to show the effect on
uranium air activities of rolling uranium metal as being highest during rolling.

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McKeel_ADD-2_AllenNov12.doc

Dan McKeel. This circuitous routing seemed to be designed to cause the maximum
possible confusion and delay. It seems that even though the requested SRDB
documents are DOE-generated, that DOE must now rely on NIOSH to furnish printed
copies to the FOIA requester McKeel.

Respectfully submitted,
{

5 fy, 4 PAZ,
Darel CSW CMe } q ;

Daniel W. McKeel, Jr. 11/25/2012

Contact information:
Daniel W. McKeel, Jr., M.D.
GSI SEC-00105 co-petitioner

Attachment: EXHIBIT 1 Weldon Spring uranium dingot photograph



McKeel_ADD-2_AllenNov12.doc

Tables 1 through 3 that follow represent the newly compiled data sorted by
database field variables “SITE_TYPE” and “SITE_NAME” in ascending order. All of the
data variables listed under Layout 1, page 2, are represented in Tables 1-3 to follow.

TABLE 1 Filemaker Pro Layout 2, List Site Data (1 page)

ee ALLEN_SDs tes _. ps

11252012 SITES NAMED ALLEN AUG-NOV 2012 ?
SITE T_CLAIMS T_CASES C_CLAIMS  C_CASES PAID_CASES —PAID_AMT = DR_TOTAL DR_DONE —DR_APPROVE
(GSI) General Steel __957 595 588 333 72 $10,737,500 288 253 66
Simonds Saw & Steel __61S 365 449 258 120 $17,847,369 208 182 77
Chambersburg 1 1 ) ) 0 $0 0 0 0
Chambersburg 1 1 0 0 0 $0 oO 0 )
Heald Mschine 41 24 31 16 oO $0; $900 medical 12 uW o
RY LeBlond Machine 3 3 ° 0 ° $0 o 0 o
Tocco Induction 4 2 4 2 o $0 2 2 0
Tocco Induction 4 2 4 2 0 $0 2 2 °
Fernald Feed 2733 1920 2429 1644 551 $82,538,169 1298 1063 461
Weldon Spring Plant 824 538 570 359 175 $26,212,500 269 261 96
Weldon Spring Plant __ 824 $38 $70 359 175 $26,212,500 269 261 96
Weldon Spring Plant __ 824 538 570 359 175 $26,212,500 269 261 96
Weldon Spring Plant __ 824 538 570 359 175 $26,212,500 269 261 96

Legend. The 4 proposed Allen surrogate AWE sites—Chambersburg, Heald, LeBlond, Tocco—among
them have only 14 DRs submitted to NIOSH of which 13 have been completed and none have been paid.

TABLE 2 Filemaker Pro Layout 3, List Allen Data (1 page)

ALLEN_SDsites_.

fo5

12s/20\2 ALLEN SURROGATE AIR SAMPLE DATA °
SITE MO_2012 SITE_TYPE SRDB_NUM PAGE_NUM UR_FORM NUM_SAMPLE SAMPLE_DATE ACTIVITY
GSI) See NOTES _ AWE INDEX n/a n/a dingots, none 7 unknown
Simonds Aug AWE ROLL Not stated Not stated rolled Not stated Not stated hot stated Fig. 1
Chambersb Nov AWESD 43252 2 ‘slugs 3 3/21/2087 5-28
Chambersb Aug AWESD 10048 39 slugs unknown Not stated Fig. 3 69-77
Heald Aug AWE SD. 40986 10 slugs fot clear 5/18/60 1-11
RY LeBlond Nov AWE SD 10634 MW billets 6 8/22/2061 9-15; 4ND
Toceo Nov AWE SO 98533, 124 slugs 6 6/16/68 5-37; 1 ND
Toceo Nov AWE SO 98533 129 slugs 2 2/16/68 22,53
Fernald Nov DOE SD 34390 2 derby 9 8/19/63 34-110
Weldon Nov DOE SD 12363 a} dingots: 2 11/14/60 21-24
Weldon Nov DOE SD 12363, 22 dingots 3 2/26/61 46.62-66.6
Weldon Nov DOE SD 14956 4 slugs 3 35/30/60 25,25,25
Weldon Nov. DOE SD 17254 6 dingots 3 12/10/56 11.8, 23.7, ND

Legend. None of Allen’s 4 proposed AWE surrogate sites and 1 DOE proposed surrogate site, Weldon
Spring Plant, handled uranium dingots that were the main uranium form at GS! subjected to Betatron
NDT radiography. The derby uranium form used at Fernald was not used for NDT radiography at GS!.



McKeel_ADD-2_AllenNov12.doc

TABLE 3b Filemaker Pro Layout 4, List Notes (2 pages)

11/25/2012 ALLEN AUG-NOV 2012 AWE-DOE SITES 7
SITE PAID_CASES DR_APPROYE SITE_TYPE UR_FORM NOTES
Tocco Induction 0 0 AWESD slugs Slugs were not used at GSI. THB- 6000 slug facility surrogate site

failed Board SD criterie. 8/28/12 TBD6K work group meeting,

Tocco Induction oO o AWE SD slugs Slugs were not used at GSI. THB- 6000 slug facility surrogate site
failed Board SD criteria, 8/28/12 TBD6K work group meeting,

Fernald Feed 551 461 OE SD derby Allen Table footnote (1) (Attachment 1)

(1) “Values listed as imaodmun, miniinum and average were used as three
different samples”

© The derby form of Ur-236 was not used at GSI for NOT
radiography 1953-1966

Weldon Spring Plant 175 96 DOE SD dingots Allen Nov 2012 table, Footnotes (1) (2) of
Attachment 1

“Values listed as maxdmun, minimum and average were used as three
itferent samples”

(2) “Values beck calculated using conversion factors atthe bottom of
sunmary report”

Weldon Spring Plant 175 96 DOE SD dingots Allen Nov 2012 table, Footnotes (1)(2) of
Attachment 1
(1) “Values listed as mesénun, mininum and average were used as three
diferent samples”
(2) “Values back calculated using conversion factors at the bottom of
summary report”

‘Weldon Spring Plant 175 96 DOE SD slugs Slugs were not used at GS!. THB- 6000 slug facility surrogate site
failed Board SD criteria, 8/28/12 TBD6K work group meeting

Weldon Spring Plant 175 96 DOE SD ingots Weldon Spring plent was not in operation until 1957. Thus, these
3 samples must have been from MCW-Destrehan St. (downtown
Stl)

Legend. Note that only Weldon Spring Plant handled uranium dingots as did GSI. Yet other parameters
of this DOE Feed Materials Plant were quite different from GSI. The last entry indicates these three air
samples dated December 10, 1956, must have been from MCW in downtown St. Louis rather than from
the Weldon Spring site where work didn’t start until 1957. Note that several WS dingot values were not
actually separate sample values but rather maximum, minimum and average data values, or were back
calculated from a data summary that was not part of the Allen November 2012 Allen paper.

Dan McKeel’s Summary and Conclusions. The November 2012 Allen GSI
paper has several major weaknesses that make the air sampling data from additional
surrogate sites difficult to assess.

(1) Insufficient information about the four proposed surrogate AWE sites is
presented by Allen in order to meet the Board “stringent justification” comparability
criterion. It is obvious that none of these 4 sites is remotely comparable to GSI in any
way. Allen did not include the complete SRDB citations, and the parent documents must

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McKeel_ADD-2_AllenNov12.doc

EXHIBIT 1
Weldon Spring Site Interpretive Center
-- Uncropped rough surfaced uranium dingot --

» bs Vi" \ é ad 2
Legend. A photograph of a uranium dingot from Weldon Spring Site Interpretive Center
museum area wall display. Courtesy ~ 2009, with permission of DOE
contractor staff given to him. The height is taller than the width, unlike David Allen’s
Weldon Springs uranium dingot size that was stated to be 18 x 18 inches in his
November 2012 GSI air sample paper. It seems likely this dingot has not been cropped
or further machined, as the outer surfaces are uneven and shaggy. The size of this
photographed uranium form is not given but can be judged by the workers pant legs and
shoes in the background surrounding the dingot.



Dragon, Karen E. (CDC/NIOSHIEID)

From: DanMckeel

Sent: Monday, November 26, 2012 12:31 AM

To: pl.ziemer@comcast.net; wimunn@aol.com; josiebeach@charter.net; j-poston@tamu.edu;
Katz, Ted (CDC/NIOSH/OD); NIOSH Docket Office (CDC)

Ce: danmckeel

Subject: GSI: McKeel ADDENDUN-2 to Allen Nov. 2012 air sample paper

Attachments: McKeel_ADD-2_11.25.12.pdf

Dr. Paul Ziemer and members of the TBD-6000 work group
All members of the ABRWH

Ted Katz, DFO

NIOSH Docket 140 Office

Attachment: <McKeel_ADD-2_11.25.12.pdf> 1.2 MB
Dear Dr. Ziemer and members of the TBD-6K work group and Board, and the NIOSH Docket 140 Officer,

Please include this 8 page Addendum-2 to my previous comment and Addendum-1 comment to David Allen's two GSI
air sample surrogate data papers (Aug/Nov 2012) he has submitted for the TBD-6000 Nov. 28, 2012, work group meeting
My paper adds further site characterization of the 37 air samples, and of the AWE and DOE proposed surrogate sites vis
a vis the Board surrogate data criteria as they may apply to GSI.

| have loaded the assembled Allen and FUSRAP site information, and DOL claims statistical data by state and site, into a
Filemaker Pro database and present the results of the analysis in four Tables generated from that database. The four
proposed AWE sites and 2 DOE sites are not similar to GSI in that: (a) the AWE sites have far fewer claims, cases, DRs
submitted and none approved or paid, (b) 62.2% of the 37 uranium forms for which air samples are available do not match
those used at GSI for NDT radiographic inspections, and (c) the complete SRDB documents have not been made
available to the petitioners, so the additional air sample data cannot be adequately evaluated.

Ted Katz: Please distribute this to all work group staff and to all members of the ABRWH.
NIOSH DOCKET 140 (GSI) Office: Please consider this paper for posting on the DCAS website as an addition to my

previous comment and the first Addendum posted with it under GSI Docket 140 in the 11/28/12 TBD-6000 work group
upcoming meeting section. Thank you.

Sincerely -- Dan McKeel Nov. 25, 2012 Sunday

Daniel W. McKeel, Jr., MD
GSI SEC-00105 co-petitioner



McKeel_ADD-2_AllenNov12.doc

be examined in order for his additional site air sample data to be properly evaluated by
SC&A and the Board. The petitioners believe these reports may not have been made
available by Mr. Allen to the work group and to SC&A prior to 11/25/12.

(2) These 4 Allen surrogate AWE sites had no claims approved or paid,

(3) These 4 Allen surrogate AWE sites had 14 NIOSH DR submitted and 13 DR
completed, none of which were approved.

(4) Only 1 of the 4 Allen surrogate AWE sites, Tocco Industrial, had FUSRAP
data.

(5) Board surrogate data criterion 1, “hierarchy of data,” therefore is not met in
that the AWE surrogate site data offered is more advantageous than GSI, the INDEX
AWE site against which all surrogate sites must be compared, only in that a few
fragmentary “cold uranium” air samples are available. GS! operations with uranium are
different, involving Betatron NDT irradiation of the MCW uranium dingots using a special
uranium shield made at MCW that was in use as early as November 1952. We have
attached as EXHIBITS 1 and 2 conclusive proof the GSI, Granite City, IL, 24 Mev
Betatron was in use in January 1952.

(6) Allen's final list of 37 uranium air samples in the Table, Attachment 1 of his
November paper, includes (n=14) slug samples and (n=9) derby samples that represent
types of uranium that were not sent by MCW to GSI to be studied by Betatron NDT
radiography. Using these 23 samples that are 62.2% or 2/3rd of total additional

Allen surrogate air samples is not acceptable: GS! studied mainly uncropped
uranium dingots, plus fewer uranium billets and “Betatron slices.” The TBD-6000 slug

facility (not named) was discredited by the TBD-6000 work group on 8/28/12. Mr. Allen
was unwilling, however, to admit the GSI Appendix BB intake model was not bounding.
The latter form is not represented in Allen’s August or November surrogate data.

(7) Mr. Allen indicates that all of these additional surrogate air samples will be
used in a revised Appendix BB sometime in the future. No specific intake model is
proposed to replace the existing one, and it is not clear exactly what method will be
employed to calculate uranium intakes in a revised Appendix BB. Standard parameters
for calculating uranium intakes include ambient general air samples, breathing zone
samples, process samples, and urinary uranium bioassays, none of which are available
at GSI. The type of air samples Mr. Allen lists in the Table accompanying Attachment 1
of his November 2012 GSI intake paper is not clear.

(8) Some photographs of Weldon Spring uranium dingots clearly show their outer
surface is very rough due to the adherent Magnesium-Fluoride slag, and the dingot (see
EXHIBIT 1) is obviously taller than it is wide. Mr. Allen’s figure of 18 by 18 inches for
Weldon Springs (sic) uranium dingots is therefore suspect; his primary documentation
source for stating this “fact” is not given.

(9) Back calculating summary data to obtain data points and using maximum,
minimum, and average values as three individual sample values are misleading, not
standard, and thus unacceptable statistical practices.

(10) Co-petitioner McKeel was told by DCAS Director Hinnefeld that he must
request the SRDB documents, not all of which could be identified by author, title,
volume and report number and date, via the FOIA route, and that the request should be
routed first through the CDC/ATSDR FOIA office, which would pass the request to DOE,
which would then obtain electronic copies from NIOSH that could finally be routed to

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ae ee ee

McKeel_ADD-2_AllenNov12.doc

Daniel W. McKeel, Jr., M.D.
GSI SEC-00105 Co-petitioner
ADDENDUM-2 Comment on November 2012 |
David Allen GSI Additional Surrogate Data
Discussion Paper
(11/24/12)

Background

This comment further analyzes all of the additional AWE and DOE sites that
David Allen proposes in his August and November 2012 GSI Discussion papers. The
November 2012 Allen paper will be a focus of the TBD-6000 work group at its 11/28/12
meeting. The issue is whether or not these additional sites can substitute for the slug |
facility air sampling data for “cold uranium” handling referred to in Battelle TBD-6000 |
that failed to meet 4 of 5 Board surrogate data criteria (SC&A Robert Anigstein review |
paper) at the 8/28/12 meeting of the same work group. The alternate GSI uranium
intake (inhalation) model in Appendix BB proposed by SC&A was also found not to be
valid based on new petitioner information that both the Old and New GSI Betatron
buildings had been power washed repeatedly during the residual contamination period.

Dan McKeel’s analysis is that none of these additional proposed surrogate sites
comes close to satisfying the Board's “stringent justification” criterion 2 or the “process
similarity” criterion 4 for surrogate data. The remainder of this paper summarizes all of
the data Dan McKeel can gather about these sites, and presents added data on the
number of claims and cases filed, approved and paid under EEOICPA part B in this
paper. and that have dose reconstructions (DR) done by NIOSH. Part E results were
not analyzed for the two DOE sites—Weldon Spring and Fernald—that are proposed for
surrogate sites.

Petitioner Data Analyses and Results

David Allen’s data from his August and November 2012 GSI uranium air sample
Discussion papers was combined in a personal computer database, Filemaker ProTM,
using four different layouts (report formats) to present the data. The AWE proposed
surrogate sites included LeBlond, Chambersburg, Heald Machine (August paper
only), and Tocco Industrial (November paper only). Simonds Saw and Steel was
included only in the August 2012 Allen paper to show that uranium activity in air
samples was higher during uranium metal rolling than afterwards. DOE sites added by
Allen in his November 2012 paper included Fernald and Weldon Spring.

The co-petitioner added additional data from the Department of Energy FUSRAP
covered facilities and considered sites database listings. EEOICPA claims data was
taken from 11/17-21/12 DOL website “EEOICPA state and site” statistics for the Allen
surrogate sites as well as for General Steel Industries (“GSI”), the index AWE site. The
data variables used may be seen in the Layout 1 report for GSI (see page 2). The
meaning of each variable is explained in the legend on the following page.

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McKeel_ADD-2_AllenNov12.doc

ALLEN_SDsites_2012.fp5

SITE
T_CLAIMS
T_CASES
C_CLAIMS
C_CASES
PAID_CASES
PAID_AMT
DR_TOTAL
DR_DOHE
DR_APPROYE
MO_2012
SITE_TYPE
SRDB_HUM
PAGE_HUM
UR_FORM
ACTIVITY
STATE
HUM_SAMPLE
SAMPLE_DATE

NOTES [GSI is the INDEX SITE against which all Allen
proposed surrogate data sites are assessed a3
“stringently justified” for process similarity.
GSI petitoners assert no Allen proposed SD site
passes this criterion, Slugs, derbies not subjected
to NOT radiography at GS1 1953-1966 during the
IMEC contract period. New petitioner info indicates
Betatron NDT also was done at GSI Nov-Dec 1952.

Legend. Data variables are derived from DOL website for Part B only. They include: SITE (name of site), T_.CLAIMS
(total claims), T_CASES (total cases), C_CLAIMS (covered claims), C_CASES (covered cases), PAID_CASES (no.
of cases compensated), AMT_PAID (amount of money paid under Part B to date for site), DR_TOTAL (total dose
reconstructions submitted to NIOSH), DR_DONE (Dose reconstructions that NIOSH has completed to date for site),
DR_APPROVE (NIOSH dose reconstructions that have been approved, i.e. POC equal to or greater than 50.0%),
MO_2012 (refers to month in 2012 that David Allen’s paper was released, SITE_TYPE (was the EEOICPA site
primarily AWE or DOE for the operational period), SRDB_NUM (NIOSH site research database number as given by
David Allen), PAGE_NUM (NIOSH site research database PDF document page number as given by David Allen),
UR_FORM (forms of uranium handled at the site), ACTIVITY (air sample radioactivity of uranium in dpm/m*), STATE
(U.S. state the site is located in), NUM_SAMPLE (number of air samples from site in Allen's 2 papers, SAMPLE-
DATE (air sample dates by Allen on sheets (Aug) or Attachment 1 table (Nov paper), NOTES (added by DWM).

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